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a ~ ~ <br />Infornlation froth these offices was interpreted to contain conflicting information during appeal review, as <br />was noted in the decision remand/reverse letter to the GMUG from the Rocky Mountain Regional Office. <br />Following the reversal/remand, the GMUG made additional contacts with the District 9 MSHA Office, <br />which has- the approval authority and jurisdiction to regulate mines in Colorado, to clarify information <br />from the project record and to further evaluate the feasibility of methane flaring. The results of this <br />additional research are described below. <br />Evaluation of Feasibility of Methane Flaring <br />Flaring of methane gas from MDWs was identified as a potential way to reduce greenhouse gas emissions <br />to the atmosphere. Hence, the question of the feasibility of flaring from MDWs was brought forward. <br />From further contacts with MSHA, the GMUG found that while MSHA regulations may not specifically <br />prohibit flaring, it is not a feasible alternative because it is an un-researched and untested technology; <br />there are too many unknowns about flaring systems in general for 1~1SHA to approve at the West Elk <br />Mine in particular; and therefore, it cannot be analyzed as a reasonable altemative..Additional discussion <br />is provided below. <br />MSHA's District 9 Office in Lakewood, Colorado is the office with responsibility to approve mining <br />plans for all coal mines in the western US (see Attachment 1 to this document). This responsibility <br />includes approving mine ventilation plans. In the case of Mountain Coal Company's West Elk Mine (the <br />mine for which E Seam MDWs Project is being reviewed}, MSHA has approved a ventilation plan that <br />includes MDWs (also called de-gas wells). Therefore, the mining company must have MDWs in order to <br />comply with the approved plan. The currently approved ventilation plan does not contain provisions for <br />flaring. MSHA has advised the mine operator that too many unknowns exist at the present time for <br />MSHA to approve a flaring system. <br />In response to Forest Service inquiries regarding the feasibility of methane flaring, MSHA District 9 <br />Office responded that their office must ensure safety of persons working underground, and any flaring <br />system envisioned that. is more or less connected to the active gob where miners work must have a full <br />MSHA evaluation and determined to be of safe design. To this end, MSHA stated that any flaring system <br />design would need to be tested in a situation in which no miners are exposed (such as at a sealed and <br />abandoned mine), and for sufficient time to test the viability and durability of the system to ensure that <br />there would be zero potential to cause gas ignition underground (Attachment 1 of this document). MSHA <br />believes testing and analysis .would require several years of effort. <br />Further, MSHA District 9 reviewed a conceptual flare design, and emphasized there are too many <br />questions remaining unanswered, no evaluations and no actual testing in a no-risk mine type situation that <br />demonstrates the conceptual flaring system would be safe.. <br />While NEPA requires that feasible alternatives be considered even if they are outside the jurisdiction of <br />the lead agency, methane flaring cannot be considered in detail at this time because the technology is <br />unproven and has unknown unanalyzed safety hazards. As flaring has not undergone rigorous analysis <br />pertaining specifically to this mine to account for specific operating conditions, or to any active coal mine <br />in the US, it is not a feasible alternative to consider in detail for this analysis. <br />44 <br />